Transportation/Air Quality Issues in Rural AreasBack to Search Page

Federal Highway Administration

Transportation/Air Quality

Issues in Rural Areas

Final Report

April 2003

Prepared by

Dye Management Group, Inc.

500 108th Avenue NE, Suite 1700

Bellevue, WA 98004

Federal Highway Administration

Transportation/Air Quality Issues in Rural Areas

Table of Contents

I. Introduction

A. Background

B. Approach

C. Report Structure

II. Summary of Findings

III. Identification of Isolated Rural Areas

IV. Survey Results

A. Carbon Monoxide

B. Ozone

C. Particulate Matter-10

Appendix A: Survey A-1

Federal Highway Administration

Transportation/Air Quality Issues in Rural Areas

I. Introduction

Although air quality has been mainly an urban concern, it is beginning to 

become

an issue that rural areas will also have to manage. Several rural counties 

have

exceeded the national standard for one or more air pollutants. The purpose of

this study is to increase understanding of how many rural areas are facing 

this

problem and to identify the main causes for their exceeding air quality

standards. The study also focuses on transportation's contribution to the air

quality problems in rural areas and how these areas are meeting certain Clean

Air Act requirements related to motor vehicle emission sources. In order to

build this understanding, the research identified rural nonattainment and

maintenance areas: how many are there, where are they, and are they isolated

rural areas or donut areas? (These two different types of areas are defined in

Section III.) Once the delineation of areas was accomplished, the study's

in-depth evaluation of air quality and transportation conformity issues was

restricted to only isolated rural areas.

The research reported in this paper accomplished the following:

Determined if transportation is generating the pollutants in each isolated

rural area or if another source is primarily responsible for the pollutant.

Identified what analysis rural areas have conducted to meet the Clean Air 

Act

requirements for transportation conformity and the control measures they 

have

undertaken to address transportation-related sources of pollutants.

Assessed the resources and planning capabilities of isolated rural areas to

address the issue of conformity between transportation plans for their areas

and State Implementation Plans (SIPs).

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A. Background

The conformity provisions of the Clean Air Act are intended to integrate

transportation and air quality planning in areas that are designated by the US

Environmental Protection Agency (EPA) as nonattainment or maintenance.1 The

transportation conformity process establishes a connection between

transportation planning and the emissions levels for transportation sources 

that

are established in the SIP. These emissions levels (or "budgets") in the SIP

represent the maximum amount of emissions that can be generated from on-road

transportation sources (e.g., cars, trucks, public transit) and still allow 

the

area to attain or maintain the air quality standards. Under the CAA,

nonattainment and maintenance areas must demonstrate through the conformity

process that emissions projected from their transportation investments,

strategies, and programs will be at or below the emissions budgets in the SIP.

In order to comply with the National Ambient Air Quality Standards, federal,

state, and local governments must take action. These actions, or control
measures, are typically identified in the SIP. Depending on the classification

and severity of the air quality problem, some areas may find that they need to

reduce emissions from transportation sources. One option for reducing 

emissions

for on-road mobile sources is to limit vehicle miles traveled (VMT). VMT is 

the

sum of distances traveled by all motor vehicles in a specified region. In 

order

to address VMT, some states have included Transportation Control Measures 

(TCMs)

as strategies that are specifically identified and committed to in the SIP. 

TCMs

are strategies that are listed in Section 108 of the Clean Air Act and include

projects such as public transit and ride-share programs. Areas might also 

invest

in other technology-based strategies that will reduce transportation-related

emissions such as inspection and maintenance and fuels programs.

1 A nonattainment area is a region that does not meet (or that contributes to

ambient air quality in a nearby area that does not meet) the national primary 

or

secondary ambient air quality standard for the pollutant. The area must take

specified actions within a certain time frame to reduce emissions and attain 

the

National Ambient Air Quality Standards (NAAQS). A maintenance area is a region

previously designated as nonattainment, and subsequently redesignated to

attainment.

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B. Approach

To meet the objectives of this study, research was conducted to determine the

classification of areas. A comprehensive survey was designed, administered, 

and

analyzed. The entire process was overseen by officials from the FHWA and EPA

Office of Transportation and Air Quality (OTAQ).

Oversight

Study oversight was provided by officials from the FHWA and EPA-OTAQ. The

following officials were involved in the study oversight:

Bob Gorman, FHWA

Dee Spann, FHWA

Cecilia Ho, FHWA

Angela Spickard, EPA-OTAQ

The oversight group provided input and validated the study at key points,

including study inception, survey design, and presentation of findings.

Research and Analysis

August 2001 data on rural nonattainment and maintenance areas was compiled

from the EPA Greenbook website (http://epa.gov/oar/oaqps/greenbk/). The EPA

Greenbook data included information on all nonattainment and maintenance 

areas

in the United States for six pollutants: ozone, carbon monoxide, nitrogen

dioxide, sulfur dioxide, particulate matter, and lead. The data also

distinguished between nonattainment and maintenance areas that are part of a

Metropolitan Planning Organization (MPO) and those that are not. In this

research, the three transportation-related pollutants examined were carbon

monoxide, ozone, and particulate matter-10 (PM-10). Although nitrogen 

dioxide

is also a pollutant emitted from transportation sources, there are no 

isolated

rural areas violating the nitrogen dioxide air quality standard. A list of

nonattainment and maintenance isolated rural areas was compiled.

In order to differentiate between the isolated rural areas and the donut

areas, many sources of information were used. (The two types of rural areas

are defined in Section II.) The Association of Metropolitan Planning

Organizations (AMPO) was consulted for determining which geographic areas 

MPOs

covered. Organizational websites (where available) were used to determine 

the

exact coverage area of the MPO; an organization without a website was

contacted by phone. The MPO areas were mapped out, as were the nonattainment

and maintenance areas, to determine if the area was a donut or an isolated

rural area. The regional EPA offices were contacted by phone to verify the

list of isolated rural nonattainment/maintenance areas and the donut areas.

The Code of Federal Regulations was consulted to determine the current air

quality classification of the area and to incorporate any updates since the

Greenbook data was last updated in August 2001. The analysis and survey

conducted was based on designations as of mid January 2002.

Survey

In conjunction with the EPA and the FHWA, a survey was developed to 

determine

how isolated rural areas designated as nonattainment or maintenance for one 
or

more national ambient air quality standards are addressing air quality and

transportation conformity requirements. The survey specifically addresses

Ozone, Carbon Monoxide, and PM-10 isolated rural areas. The main questions

addressed in the survey are:

Why are these isolated rural areas in nonattainment or maintenance (i.e.,

what are the main sources of their air quality problems)?

How are these air quality problems being addressed by the different 

agencies

involved?

How are these areas meeting the transportation conformity requirements?

The survey was e-mailed to the state department of transportation and state

air quality agency for each area. In addition, regional FHWA and regional 

EPA

offices were also e-mailed a survey. The consultant team answered survey

respondents' questions and encouraged those who had not completed a survey 

to

do so.

Interviews

One jurisdiction from each pollutant nonattainment or maintenance area --

Presque Isle, Maine; Fairbanks, Alaska; and Greenbrier County, West Virginia

-- was selected for a follow-up interview. These focused discussions were 

used

to clarify how the area has used the conformity process and to identify the

practical issues associated with different aspects of the process. The

interviews confirmed the conclusions the study team reached from the survey

data.

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C. Report Structure

This report is organized into the following sections:

II. Summary of Findings. This section presents the general findings from the

surveys collected for all the isolated rural nonattainment and maintenance

areas that responded.

III. Identification of Isolated Rural Areas. This section identifies which

rural areas are isolated and which areas are donut areas.

IV. Survey Results. This section presents a detailed summary of the survey

responses for isolated rural areas organized by pollutant.

V. Appendix A: Survey. This appendix contains the text of the survey

administered by Dye Management Group, Inc. in June 2002.

Back to Table of Contents

II. Summary of Findings

The following summarizes the major findings of a study that assessed the 

process

and techniques that isolated rural nonattainment and maintenance areas have 

used

to address the requirements of the conformity process. More details and

definitions can be found in the body of this report.

There are few isolated rural nonattainment or maintenance areas compared to

the total nonattainment or maintenance areas for each pollutant.

Isolated rural nonattainment or maintenance areas represent a small 

percentage

of the total nonattainment or maintenance areas, as shown in Exhibit II-1.

Exhibit II-1: Number of Isolated Rural Nonattainment

or Maintenance Areas Relative to

Total Nonattainment or Maintenance Areas in 2001PollutantIsolated Rural

AreasTotal areasPercent Isolated Rural

Carbon Monoxide31212

Ozone314207

PM-103710635

The exhibit reinforces a predominant view that air quality is primarily an

urban concern. However, the portion of PM-10 areas that are isolated rural

areas is significant.

In only two cases were more than 5 percent of the PM-10 emissions attributed

to on-road mobile sources.

Survey results indicated that in most of the isolated rural areas the PM-10

problem in an area are attributable to sources other than on-road mobile

sources such as point source (e.g., factories or power plants). 

Consequently,

transportation-related strategies did not really help these areas to attain

the PM-10 standard.

Experience with PM-10 problems in other areas, confirmed through the survey

and telephone follow up with the isolated rural areas, indicates that more

frequent street sweeping, changing deicing materials or other fugitive dust

control measures can be effective in reducing PM-10 emissions. In the case 

of

Presque Isle, Maine, (a PM-10 nonattainment isolated rural area) switching

from a native sanding material to calcium chloride was very effective in
reducing PM-10 emissions. However, the cost of using the chemical in place 

of

the sand had prevented the local maintenance crews from switching for many

years.

The isolated rural areas have limited staff resources to understand and

address the implications of nonattainment status.

In general the isolated rural areas do not have professional air quality and

transportation planning staff. Local jurisdictions' responsibilities are

typically addressed through their public works department or county engineer

depending upon their organizational structure. They also rely on the 

expertise

of State Department of Transportation staff in addressing conformity issues.

There is typically limited local data and planning information to perform

conformity analysis.

The survey results indicate that in those few cases where analysis is

performed, traffic data and growth estimates are derived from traffic counts

and other traffic monitoring data reporting such as HPMS. Few areas 

indicated

that they collected local data.

Interagency consultation is helpful when needed, but most survey respondents

have never held a meeting of all federal, state, and local agencies because

they have not had transportation projects, and therefore, have not needed to

determine conformity.

Ten of the 18 survey respondents stated that there had never been a meeting

among all agencies for the area, while two respondents explained that they

have not needed consultation because the area has had no new projects. Three

respondents did not provide any information about consultation for their

isolated rural area.

The three respondents that endorsed interagency consultation stated that the

process has been helpful in facilitating cross-functionality training and

resolving conformity issues. According to the Chief of EPA Region 4's Air

Planning Branch, interagency consultation has been very effective in 

Edmonson

County, Kentucky:

Effective interagency consultation was the key to resolving this issue and

could have been used as the means to prevent any delay from occurring.

Because of this area's limited experience with conformity and the nature 

of

how transportation conformity is implemented in isolated rural areas 

(i.e.,

until projects are seriously contemplated there is no need to do 

conformity

analysis), planning parties may not have allowed time for any resolution 

to

potential issues, and may not have effectively consulted with parties who

could work to resolve issues until there was no choice but for delay. In

this case, it was not until the area ran the conformity analysis and was 

not

able to demonstrate conformity to a budget developed with the Mobile 4.1

emissions model that the area realized that it would be beneficial for 

them

to have mobile emissions budgets developed with the new Mobile 5 emissions

model. The efforts for developing new emissions budgets is not extremely

burdensome but does require planning, review and approval on the part of

various agencies that may not have been alerted to this situation until it

was too late.

The Kentucky Transportation Cabinet and air quality partners in the 

Edmonson

County have gained a lot from their interagency coordination and 

communicate

on at least a monthly basis on this area and other areas in Kentucky, even

though the area has successfully demonstrated conformity. The partners are

taking a more proactive approach and discuss any upcoming projects that 

may

be considered for Edmonson County. In fact, this interagency consultation

discussion prevented KYTC (the Kentucky Transportation Cabinet) from

performing conformity analysis unnecessarily for Edmonson County in the

beginning of 2002. KYTC was under the impression that conformity

determinations for isolated rural areas have a three year expiration just 

as

in metropolitan areas. When this topic was discussed on the monthly

interagency consultation call, Kentucky transportation and air quality

partners were able to discuss and resolve this issue prior to KYTC 

beginning

work for this conformity determination.

In this area, interagency consultation has been very beneficial. We all 

have

a better understanding of the role of each consultation partner with 

regard

to conformity. The air quality agencies are gaining more knowledge of the

transportation planning process, and the transportation agencies are 

gaining
more knowledge of the air quality process.

Most areas reported no new Federal non-exempt transportation projects in the

past five years.

Consistent with their rural nature, 11 areas indicated no regionally

significant projects. Only three survey respondents reported non-exempt

transportation projects requiring conformity analysis over the past five

years.2 Each of the three areas only had one such project.

Two areas used an analysis period shorter than the required analysis period 

in

their conformity determination.

Although conformity analysis requires a 20-year analysis period, two areas

reported a shorter timeframe. One area reported analysis 10 years into the

future; another reported analysis 15 years into the future.

2 The remaining four survey respondents did not answer the survey question

related to non-exempt transportation projects. While these could be areas that

did not have non-exempt projects, it is possible that the survey respondent 

did

not know the answer to the question.

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III. Identification of Isolated Rural Areas

Federal regulations separate rural areas into two types: isolated rural areas

and donut areas. For purposes of this survey, the distinction between an

isolated rural area and a "donut" area is as follows. An isolated rural area 

is

an area that is not part of the emissions analysis of any Metropolitan 

Planning

Organization's (MPO) transportation plan or transportation improvement program

(TIP). A "donut" area, on the other hand, is an area that is inside a

non-attainment or maintenance area boundary, but is outside the metropolitan

planning boundary (40CFR93.109(g)).

The following tables show the rural areas currently (March 2003) in

non-attainment status.

Exhibit III-1: Carbon Monoxide Nonattainment or Maintenance Rural Areas

(March 2003)StateEPA RegionIsolated Rural AreasDonut Areas

Alaska10Fairbanks

Oregon Grants Pass

Klamath Falls

Exhibit III-2: Ozone Nonattainment or Maintenance Rural Areas (March

2003)StateEPA RegionIsolated Rural AreasDonut Areas

Connecticut1Windam County (Greater Connecticut Area)

Maine1Hancock & Waldo CountiesCumberland County (Greater Portland Area)

Knox & Lincoln Counties

New Hampshire1Cheshire County

New York2Essex County

Jefferson CountyMontgomery and Greene Counties (Albany-Schenectady-Troy

Area)

Maryland3Kent & Queen Anne's CountiesCalvert and Charles Counties

(Washington, DC-MD-VA)

Virginia3White Top Mountain (Smith County)

Delaware3Sussex County

Pennsylvania3Crawford County

Franklin County

Juanita County

Lawrence County

Northumberland County

Schuylkill County

Snyder County

Susquehanna County

Warren County

Wayne County

Virginia3White Top Mountain (Smith County)

West Virginia 3Greenbrier County

Georgia4 Coweta, Forsyth and Paulding Counties (Atlanta Area)

Kentucky4Edmonson CountyPortion of Hancock County (Owensboro area)

Paducah (Livingston and Marshall Counties)Scott County (Lexington Area)

South Carolina4Cherokee County

Tennessee4 Rutherford, Sumner, Williamson and Wilson Counties (Nashville

area)

Michigan5Allegan County

Muskegon

Ohio5Clinton CountyAshtabula and Portaqe Counties 

(Cleveland-Akron-Lorain

area)

Columbiana County

Preble County
Delaware and Licking Counties (Columbus area)

Greene and Miami Counties (Dayton-Springfield area)

Stark County (Canton area)

Louisiana6Grant Parish

Lafourche Parish

St. James Parish

St. Mary Parish

Exhibit III-3: PM-10 Nonattainment or Maintenance Rural Areas

(2003)StateEPA RegionIsolated Rural AreasDonut Areas

Maine1Presque Isle (Aroostook County)

Illinois5Oglesby (La Salle County)

Indiana5Vermillion County

New Mexico6 Anthony (Dona Ana County)

Colorado8Telluride (San Miquel County)

Pagosa Springs (Archuleta County)

Canon City (Fremont County)

Aspen (Pitkin County)

Lamar (Prowers County)

Steamboat Springs (Routt County)

Montana8Columbia Falls (Flathead County)

Whitefish and vicinity (Flathead County)

Kalispell (Flathead County)

Polson (Lake County)

Libby (Lincoln County)

Lame Deer (Rosebud County)

Thompson Falls and vicinity (Sanders County)

Ronan area (Lake County)

Butte (Silver Bow County)Ronan

Wyoming8Sheridan County

Arizona9Douglas (Coachise County)

Paul Spur (Coachise County)

Hayden/Miami (Gila and Pinal Counties)

Payson (Gila County)

Mohave County

Nogales (Santa Crus County)

California9Mammoth Lake (Mono County)

Owens Valley (Inyo County)

Mono Basin (Mono County)

Alaska10Juneau

Idaho10Sandpoint (Bonner County)

Shoshone County (excluding Pinehurst)

Pinehurst (Shoshone County)

Oregon10Lake County

Grants Pass (Josephine County)

LaGrande (Union County)

Klamath County (Klamath Falls area)

Washington10Wallula (Walla Walla County)

The study team surveyed a sample of the isolated rural areas identified in the

exhibit.

IV. Survey Results

The survey was administered to a sample of the carbon monoxide, ozone, or 

PM-10

nonattainment or maintenance isolated rural areas. The survey was sent to 41

isolated rural areas: 2 carbon monoxide nonattainment or maintenance areas, 6

ozone nonattainment or maintenance areas, and 34 PM-10 nonattainment areas.

(Grant's Pass, Oregon is both a carbon monoxide maintenance area and a

particulate matter nonattainment area.) For each area, the survey was sent to

the corresponding:

State department of transportation (DOT).

State and/or local air quality agency.

FHWA Division and EPA Regional offices.

A total of 18 surveys were completed, for an overall response rate of 43

percent. However, response rates differed according to pollutant: 100 percent

for ozone; 50 percent for carbon monoxide; and 32 percent for particulate

matter-10. Below are general conclusions from all surveys, as well as

conclusions drawn for each of the pollutants.

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A. Carbon Monoxide

Only one of the two carbon monoxide maintenance or nonattainment areas 

responded

to the survey, as shown in Exhibit IV-1.

Exhibit IV-1: Carbon Monoxide Nonattainment and Maintenance Isolated Rural

AreasStateCountyArea NameStatusClassEPA RegionCompleted Survey

AlaskaFairbanks EdFairbanksNonattainmentSerious10No

OregonJosephineGrants PassMaintenanceN/A10Yes
Over 50 percent of Grants Pass's carbon monoxide emissions is caused by 

on-road

mobile sources. VMT is projected to grow 0.8 percent per year between 1993 and

2015, as determined by a model developed in collaboration between the Rogue

Valley Council of Governments and the Oregon Department of Transportation.

Grants Pass has a maintenance SIP, which contains one transportation control

measure: wintertime oxygenated fuel. The survey respondents also indicated 

that

the one federal action that has helped the area maintain air quality standards

is improved vehicle emissions standards on new cars.

Grants Pass used the less than 1990 test and the build/no-build test in its 

last

conformity determination. For years beyond the timeframe of the SIP, Grants 

Pass

uses the budget test and demonstration using air quality modeling. It is not

clear from the survey responses why Grants Pass appears to have used both the

budget test and an air quality modeling demonstration for conformity in years

past the SIP.

Grants Pass, like all Oregon local jurisdictions, is required to develop a

transportation system plan (TSP) and receives financial support to do so. This

requirement has likely led to an improved capacity to handle planning efforts

such as the conformity process.

While the sample size for carbon monoxide nonattainment and maintenance areas 

is

small, there may be opportunity for Fairbanks to learn from Grants Pass. Since

both areas are in EPA Region 10, EPA officials could coordinate a meeting

between officials in both areas.

Comments on the Process

A survey respondent from the FHWA Division office made the following 

comment:

The FHWA Division must rely heavily on the Oregon DEQ and USEPA for

information on how and when areas are designated as non-attainment or

maintenance areas and how conformity needs to be addressed in each. If new

guidance were developed, the most useful would be something that could 

make

it easier to track the status of each specific area. Often when changes in

requirements are published in the Federal Register, it can be difficult 

and

time consuming to determine which areas are impacted and the actions that

may be needed.

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B. Ozone

All six isolated rural areas in nonattainment or maintenance for ozone, in the

survey sample, completed the survey. The areas are listed in Exhibit IV-2.

Exhibit IV-2: 2002 Ozone Nonattainment and Maintenance Isolated Rural Areas

StateCountyArea NameStatusClassEPA RegionCompleted Survey

DelawareSussexSussex CountyNonattainmentMarginal3Yes

KentuckyEdmonsonEdmonson CountyMaintenanceN/A4Yes

Livingston and MarshallPaducahMaintenanceN/A4Yes

New YorkEssexEssex CountyNonattainmentMarginal2Yes

VirginiaSmythWhite Top MountainNonattainmentMarginal3Yes

West VirginiaGreenbrierGreenbrier CountyNonattainmentN/A3Yes

Four ozone nonattainment or maintenance areas have SIPs; two areas (White Top

Mountain and Sussex County) do not. For emissions dealing with ozone, areas 

list

precursors: nitrogen oxides (NOx) and/or hydrocarbons (VOC). On-road mobile

sources of NOx ranged from 0 percent for White Top Mountain to 87 percent for

Greenbrier County. On-road mobile sources of VOC ranged from 0 percent for 

White

Top Mountain to 53 percent for Greenbrier County. Exhibit IV-3 shows the full

results of the survey.

Exhibit IV-3: Percentage of Emissions from On-road Mobile SourcesArea

NameNOx VOC

Sussex County 21%22%

Edmonson County63%36%

Paducah, Kentucky33%3%

Essex CountyN/AN/A

White Top Mountain0%0%

Greenbrier County87%53%

Notes:N/A = not reported

Sussex County, White Top Mountain, and Greenbrier County use 1990 data.

Paducah and Edmonson County use 2002 data.

Using historical data from the federal Highway Performance Monitoring System

(HPMS), VMT growth in Edmonson County is determined to be 2.28 percent 

annually

from 2000 to 2020. HPMS data was also used to determine the annual increase of

VMT in Paducah, which is 2.05 percent for Marshall County and 2.11 percent for

Livingston County. None of the other areas reported VMT information, and none 
of

the four areas with a SIP employ transportation control measures. However,

several areas listed federal actions that have helped the area attain or

maintain the air quality standards. Exhibit IV?4 lists those effective federal

measures cited by the areas.

Exhibit IV-4: Effective Federal Measures for Attaining or Maintaining Air

Quality StandardsArea NameMeasures Cited

Sussex CountyNone.

Edmonson CountyAll measures, including federal vehicle emission controls

and fleet turnover.

PaducahFleet turnover, non-road rules, the national low emission vehicle

program (NLEV), and heavy duty diesel program.

Essex CountySection 126 rule for NOx transport.

White Top MountainNone.

Greenbrier CountyFederal Motor Vehicle Control.Program (FMVCP), Heavy 

Duty

Diesel Rule, and small spark ignition gasoline engines.

For those areas with SIPs, Exhibit IV-5 lists conformity tests used both in

their conformity determination and in the years beyond the timeframe of the 

SIP.

(Only two areas provided information.)

Exhibit IV-5: Conformity TestsAreaLast DeterminationDeterminations in

Years Beyond Timeframe of SIP

Budget testLess than 1990 testBuild/no build testNo-greater-than 1990

testBudget testLess than 1990 testBuild/no build testNo-greater-than 

1990

testDemonstration using air quality modeling

Edmonson CountyX X

PaducahX X

Total Number2 2

Both Edmonson County and Paducah reported having non-exempt transportation

projects in the past five years. Edmonson determined conformity for its 

project

in 1999. Paducah failed in 1998 to determine conformity due to an increase in

VMT, but eventually the area was able to make a conformity determination in

Spring 2002 after revising its SIP to incorporate new data.

Comments on the Process

A state transportation engineer commented on the survey: "A recent ruling 

that

an isolated rural area need only do conformity when adding a new project 

will

help." The same engineer noted that "It doesn't seem appropriate to be

spending so many resources and creating local headaches over adding a minor

amount of VMT when the mobile contribution to pollution in the area is so

small anyway. For most isolated rural areas, the primary contribution is

likely coming from outside the area, so why not focus attention and 

resources

on the real problem?"

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C. Particulate Matter-10

Only 11 of the 34 PM-10 nonattainment and maintenance areas, in the survey

sample, completed the survey, as shown in Exhibit IV-6.

Exhibit IV-6: 2002 PM-10 Isolated Rural Nonattainment and Maintenance

AreasStateCountyArea NameStatusClassEPA RegionCompleted Survey

MaineAroostookPresque IsleMaintenanceN/A1Yes

ColoradoSan MiguelTellurideMaintenanceN/A8No

ArchuletaPagosa SpringsMaintenanceN/A8No

FremontCanon CityMaintenanceN/A8No

PitkinAspenNonattainmentModerate8No

ProwersLamarNonattainmentModerate8No

RouttSteamboat SpringsNonattainmentModerate8No

MontanaFlatheadColumbia FallsNonattainmentModerate8No

FlatheadFlathead County; Whitefish and vicinityNonattainmentModerate8No

FlatheadKalispellNonattainmentModerate8No

LakePolsonNonattainmentModerate8No

LincolnLibbyNonattainmentModerate8No

RosebudLame DeerNonattainmentModerate8No

SandersSanders County (part); Thompson Falls and

vicinityNonattainmentModerate8No

Silver BowButteNonattainmentModerate8No

WyomingSheridanSheridanNonattainmentModerate8Yes

ArizonaCochiseDouglasNonattainmentModerate9No

CochisePaul SpurNonattainmentModerate9No

GilaHayden/MiamiNonattainmentModerate9No

GilaPaysonNonattainmentModerate9No

MohaveMohave CountyNonattainmentModerate9No

PinalHayden/MiamiNonattainmentModerate9No

Santa CruzNogalesNonattainmentModerate9No

CaliforniaMonoMammoth LakeMaintenanceN/A9Yes

InyoOwens ValleyNonattainmentSerious9Yes
InyoSearless ValleyNonattainmentModerate9Yes

MonoMono BasinNonattainmentModerate9Yes

AlaskaJuneau EdJuneauNonattainmentModerate10No

IdahoBonnerSandpointNonattainmentModerate10Yes

ShoshonePinehurstNonattainmentModerate10Yes

OregonLakeLake CountyNonattainmentModerate10Yes

JosephineGrants PassNonattainmentModerate10Yes

UnionLaGrandeNonattainmentModerate10Yes

WashingtonWalla WallaWallulaNonattainmentSerious10No

All 11 PM-10 nonattainment or maintenance areas reported having a SIP. The

contribution of emissions from on-road mobile sources to the areas' air 

quality

problem varied and was difficult to determine in some areas. For Presque Isle,

Maine, on-road mobile-sources, including road dust, was estimated to be 61% of

the area's total PM inventory in 1994; more recent estimates show that the

percentage of direct emissions only is estimated at 7.3 percent. For Mammoth

Lakes, direct emissions from transportation sources has been determined to be

less than 1%, however, emissions from resuspended road dirt and cinders is

estimated to be 56.1% of the areas' emissions inventory. Unfortunately, survey

information did not indicate what percentage of the resuspended road dirt was

from roads versus what percentage is from cinders. Exhibit IV-7 illustrates 

the

percentage of on-road mobile emissions by area.

Exhibit IV-7: Percentage of Emissions from On-road Mobile SourcesArea

NameYear of InventoryPM-10

Presque Isle (Maine)199461*

Sheridan (Wyoming)1988N/A

Mammoth Lake (California)1988Less than 1

Owens Valley (California)1995Less than 1

Searless Valley (California)N/ALess than 1

Mono Basin (California)N/ALess than 1

Sandpoint (Idaho)19943

Pinehurst (Idaho)19882

Lake County (Oregon)N/AN/A

Grants Pass (Oregon)198610

LaGrande (Oregon)19865

Notes:N/A = not available

An interview with Presque Isle revealed problems with the 1994 measurement,

which included road sand with on-road mobile sources. The percentage of direct

emissions from on-road mobile sources is 7.3 percent.

However, several areas listed TCMs, shown in Exhibit IV-8.

Exhibit IV-8: Transportation Control MeasuresArea NameTCM Cited

Presque Isle (Maine)Removing de-icing and anti-icing materials as soon 

as

possible from roads.

Sheridan (Wyoming)Limiting sand and gravel usage and removing them as 

soon

as possible from a road after snow.

Mammoth Lake (California)Restricting parking, increasing transit

ridership, and reducing vehicle traffic.

Owens Valley (California)None.

Searless Valley (California)None.

Mono Basin (California)None.

Sandpoint (Idaho)Aggressive street sweeping program and anti skid 

material

specs.

Pinehurst (Idaho)None.

Lake County (Oregon)Paving gravel roads.

Grants Pass (Oregon)None.

LaGrande (Oregon)Controlling fugitive dust (winter road sanding, paving

gravel streets, etc.).

Interestingly, the most frequently listed TCMs do not fit the commonly used

definition of TCM, which includes actions to adjust traffic patterns or reduce

vehicle use. Only three of the 11 areas that responded to the survey noted

effective federal measures relating to VMT and tailpipe emissions, as 

reflected

in Exhibit IV-9.

Exhibit IV-9: Effective Federal Measures for Attaining or

Maintaining Air Quality StandardsArea NameMeasures Cited

Presque Isle (Maine)None.

Sheridan (Wyoming)None.

Mammoth Lake (California)VMT cap, phase out of non-certified wood stoves

and fireplaces, mandatory wood burning curtailment.

Owens Valley (California)N/A

Searless Valley (California)N/A

Mono Basin (California)N/A

Sandpoint (Idaho)Tier II, CAFE standards, OBD etc. -- improving fuel

economy and emission rates.

Pinehurst (Idaho)Tier II, CAFE standards, OBD etc. -- improving fuel
economy and emission rates.

Lake County (Oregon)CMAQ funds used to pave gravel roads (to reduce

transportation-related fugitive dust).

Grants Pass (Oregon)N/A

LaGrande (Oregon)Reducing transportation-related fugitive dust by paving

gravel roads.

Notes:N/A = not available

Only three PM-10 nonattainment areas reported having ever made a conformity

determination, and only one of these areas has done so within the last five

years. All three cited the build/no build test in their latest determination,

and two of the three noted the build/no build test in years beyond the 

timeframe

of their SIP. Exhibit IV-10 summarizes the responses.

Exhibit IV-10: Conformity TestsAreaLast DeterminationConformity in

YearsBeyond Timeframe of SIP

Budget testLess than 1990 testBuild/no build testNo-greater-than 1990

testBudget testLess than 1990 testBuild/no build testNo-greater-than 

1990

testDemonstration using air quality modeling

Sandpoint (Idaho) X X

Pinehurst (Idaho) X X

Grants Pass (Oregon) XX X

Total Number 13 2 1

Only Sandpoint reported having a non-exempt transportation project in the past

five years. It determined conformity for its project in 2000.

Comments on the Process

According to a Division FHWA Transportation Engineer who completed the 

survey:

Rural areas by their very nature (small, sparsely populated, relatively 

low

traffic volumes and densities, and infrequent capacity expansion projects)

should have minimal transportation related air quality problems. To the

extent that the above generalization is accurate, it begs the question of

why a regional level analysis is currently expected for such areas. 

Perhaps

consideration should be given to evaluating, and as necessary, analyzing

such areas at the project level, only. Since there is no PM-10 modeling

process, this would effectively limit the analysis to CO.

According to a state environmental agency transportation specialist who

completed the survey:

One of the biggest holes in modeling transportation emissions for 

conformity

purposes is VMT and speeds. Transportation and Air Quality agencies often

must rely on minimal or spotty data to base speed and VMT assumptions. As 

an

example, the statewide transportation emissions inventory is based on VMT

extrapolated from Federal Highways Statistics. The conformity process and

the quality of associated air quality analysis would be vastly improved 

with

consistent and reliable VMT and speed data. Rural areas would greatly

benefit if FHWA could expand the monitoring done for the Federal Highways

Statistics.

Back to Table of Contents

Appendix A: Survey

This appendix contains a copy of the survey used to collect the data for this

report.

FHWA Transportation/Air Quality Issues in Rural Areas

Background

FHWA is interested in assessing how isolated rural areas that have been

designated non-attainment or maintenance for one or more air quality standards

are addressing their transportation conformity related issues. FHWA has 

assigned

Dye Management Group, Inc. the task of identifying and describing current

practices. FHWA and EPA are considering developing additional guidance on how 

to

conduct conformity determinations in these areas, so your responses are

important to us. As part of this effort, we are seeking your collaboration to

participate in a survey.

The three main questions we hope to answer through this survey are:

Why are these isolated rural areas in non-attainment or maintenance (i.e.,

what are the main sources contributing to their air quality problems)?

Who is involved in the transportation planning and conformity processes for

these isolated rural areas and what are each agency's roles?

How are these air quality problems being addressed by the different agencies

involved?

The attached questionnaire, a product of the substantial collaboration from 

the
Federal Highway Administration (FHWA) and Environmental Protection Agency 

(EPA),

was designed to gather information on the identified issues of interest. For

each isolated rural area a questionnaire will be sent to the corresponding 

state

department of transportation (DOT), the state and/or local air agency, the

Division FHWA and Regional EPA offices, and any other applicable state or 

local

agency.

Rural Areas Defined

By definition, an isolated rural non-attainment or maintenance area is not 

part

of, or contiguous to, a metropolitan area having a population of 50,000 or 

more.

In other words, if an area is inside a non-attainment or maintenance area

boundary, but is outside of the metropolitan planning boundary, then it is

considered a "donut area," not an isolated rural area (see 40 CFR 93.109(g)). 

An

isolated rural area's transportation projects are not part of the emissions

analysis of any MPO's transportation plan or TIP (see 40 CFR 93.109(g)).

Isolated rural areas are not required under federal regulation to establish a

Metropolitan Planning Organization (MPO) or to develop transportation plans 

and

transportation improvement programs (TIP) as a result of their population 

size.

FHWA Transportation/Air Quality in Rural Areas

Questionnaire

Name: _______________________________________________________________

Position: _____________________________________________________________

Organization: _________________________________________________________

Telephone: __________________ E-mail:___________________________________

General

[Area Name] has been designated as a [nonattainment area or maintenance 

area]

for [ozone, carbon monoxide, or particulate matter-10].

Please verify that the designation(s) and pollutant(s) listed above for this

area is/are correct. If not accurate please correct as appropriate.

______________________________________________________________________________

______

______________________________________________________________________________

______

______________________________________________________________________________

______

______________________________________________________________________________

______

State Implementation Plan and Air Quality

Does this area have a SIP? ______Yes ______ No

If this area has a SIP, what control measures in the SIP help the area 

show

attainment?

______________________________________________________________________________

______

______________________________________________________________________________

______

______________________________________________________________________________

______

______________________________________________________________________________

______

If this area has a SIP, what are the emissions inventories for each source

sector (e.g., on-road mobile, stationary, etc.) listed in the isolated 

rural

area's SIP? Please answer this question separately for each pollutant or

each precursor of each pollutant for which an area is designated. For your

response, please choose the inventory year closest to 2002 and indicate 

the

units for each pollutant / precursor (e.g., tons per day, tons per year).

Or, if available, copy and attach a table listing of the emissions

inventory.

Year of Inventory = ___________

Units of Inventory = ___________

Sector:Inventory:

On-road mobile sources_______________________________
Others? Please list._______________________________

What federal actions/measures (e.g., federal vehicle emissions controls;

fleet turnover) are helping the area attain or maintain the air quality

standard(s)?

______________________________________________________________________________

______

What is the projected population growth in this isolated rural area? 

Please

provide the growth rate and indicate over what period of time this rate

applies (e.g., 2000-2020).

______________________________________________________________________________

______

______________________________________________________________________________

______

What is the projected growth rate of vehicle miles traveled (VMT) in this

isolated rural area? Please indicate the time period for which the VMT 

rate

applies.

______________________________________________________________________________

______

How is VMT information determined for this isolated rural area?

______________________________________________________________________________

______

______________________________________________________________________________

______

Is speed information determined? If so, how?

______________________________________________________________________________

______

______________________________________________________________________________

______

What agency determines the VMT and speed information for this isolated 

rural

area?

______________________________________________________________________________

______

Have the difficulties in demonstrating conformity ever resulted in the 

area

not being able to implement/approve a new transportation project?

___________ Yes ___________No

If yes, for how long was this project delayed? (If a project has been

delayed on more than one occasion, please specify how long for each 

delayed

project.)

______________________________________________________________________________

______

Transportation Planning and Conformity

Is this isolated rural area implementing any transportation control 

measures

included in the SIP to address its air quality problem?

Yes________ No ________

If so, what is/are the specific transportation control measures that this

area is implementing?

______________________________________________________________________________

______

Given that before a new Federal non-exempt project can be approved or 

funded

in an isolated rural area, a conformity determination is required. How 

many

non-exempt transportation projects for this isolated rural area in the 

past

5 years required FHWA/FTA approval?

2001 ________________________________________

2000 ________________________________________

1999 ________________________________________

1998 ________________________________________

1997 ________________________________________

Did you determine conformity in any of these years:

1997 Yes_____________No, _______ if no, why not?

___________________________________

1998 Yes_____________No, _______ if no, why not?
___________________________________

1999 Yes_____________No, _______ if no, why not?

___________________________________

2000 Yes_____________No, _______ if no, why not?

___________________________________

2001 Yes_____________No, _______ if no, why not?

___________________________________

How many years into the future were analyzed for the last conformity

determination performed for this area?

______________________________________________________________________________

______

What type of SIP(s) does this isolated rural area have and for what years 

do

they have motor vehicle emissions budgets (if applicable)? Please check 

all

that apply.

_______

This area does not have a SIP

_______

This area has a SIP, but it does not have motor vehicle emissions

budgets (e.g., a limited maintenance plan.)

_______

Attainment SIP.

What are the budget years, if budgets exist:

__________________________

_______

15 percent SIP.

What are the budget years, if budgets exist:

__________________________

_______

9 percent rate of progress SIP.

What are the budget years, if budgets exist:

__________________________

_______

Maintenance Plan.

What are the budget years, if budgets exist:

__________________________

Which of the following conformity test(s) did the isolated rural area use 

in

its last conformity determination? Please mark all that apply.

_______ Budget test.

_______ Less than 1990 test.

_______ Build/no-build test.

_______ No-greater-than 1990 test.

Which method below is being used to determine conformity in the years 

beyond

the timeframe of the SIP?

_______ Budget test.

_______ Build/no-build test.

_______ Less than 1990 test.

_______ No-greater-than 1990 test.

_______ Demonstration using air quality modeling (same modeling used in 

the

SIP).

What agency runs the emissions analysis for this isolated rural area? What

agency prepares the travel estimates (e.g., estimating VMT)?

______________________________________________________________________________

______

How many times since January 1997 has this isolated rural area determined

conformity? What were the dates (month and year) on which the conformity

determination was made for this area?

Number of determinations since 1997:

_________________________________________

Dates on which these conformity determinations were made:

_________________________________

What triggered the need for these conformity determinations? A new

transportation project, or some other reason?

______________________________________________________________________________

______
______________________________________________________________________________

______

Has this isolated rural area ever had difficulty demonstrating conformity

(i.e., they cold not pass their conformity test as listed above)? If 

answer

to this question is No, please skip to question 3-l below.

______ Yes _______ No

For what analysis years did this area have difficulty demonstrating

conformity?

______________________________________________________________________________

______

What was the nature of this area's conformity difficulties? Please check 

all

that apply.

________ Population grew faster than anticipated.

________ New data/information on fleet resulted in higher emissions.

________ Control measures ended because of a sunset date. If yes, which

measures?

______________________________________________________________________________

______

________ Control measures ended with the end of the SIP. If yes, which

measures?

______________________________________________________________________________

______

Other? Please explain briefly:

____________________________________________________________

______________________________________________________________________________

______

Why was this area not able to meet the SIP budget(s)? Please check all 

that

apply.

________ SIP was based on an earlier version of emissions factor model.

________ SIP was based on older data that was updated for the conformity

determination.

________ Area was experiencing unanticipated growth.

________ A control measure not being implemented; which measure?

______________________________________________________________________________

______

Other? Please explain.

______________________________________________________________________________

______

If this area has experienced conformity difficulties, have the 

difficulties

been successfully addressed and resolved? ______ Yes ______ No.

If yes, what factors contributed to this outcome? (Choose all that apply

from the two categories below: Revision to SIP and Revisions 

Transportation

Projects.)

Revision to SIP

_________ Identifying a safety margin and applying some or all of it to 

the

budget.

_________ Adding transportation control measures in the SIP. Which 

measures?

_________ Adding emission reduction control measures. Which measures?

______________________________________________________________________________

______

_________ Updating the budget with new data (e.g., population, employment,

etc.).

_________ Updating the budget with a new emissions factor model.

_________ Other? Please briefly explain:

______________________________________________________________________________

______

Revision to Transportation Projects

_________ Eliminating, changing scope of or delaying transportation

projects.

_________ Adding transportation control strategies (but will not be 

included

in the SIP). Which strategies?

______________________________________________________________________________

______
_________ Adding other emissions reduction measures (not already in the

SIP). Which measures?

______________________________________________________________________________

______

_________ Adjusting assumptions for new federal rules (e.g., Tier 2 new

vehicle emissions standards).

Which rules?

______________________________________________________________________________

______

_________ Other? Please briefly explain:

______________________________________________________________________________

______

What resources are available, in terms of number of staff, their skill 

level

and the amount of planning funds, at the local level to demonstrate

conformity to the SIP?

______________________________________________________________________________

______

Interagency Consultation

Who actually does the modeling and/or approves the conformity 

determination

for the isolated rural areas?

______________________________________________________________________________

______

______________________________________________________________________________

______

What federal, state and local agencies are involved in the consultation

process for this isolated rural area?

______________________________________________________________________________

______

______________________________________________________________________________

______

What are the consultation procedures for this isolated rural area? Please

check all that apply.

_______

A meeting among all agencies is held prior to a conformity analysis

(i.e., when a new project is initiated).

_______

A meeting among all agencies is held after the analysis is 

performed,

but prior to FHWA approval of the conformity determination.

_______

A meeting among all agencies is only held if the conformity analysis

indicates that the area might have difficulty demonstrating

conformity.

_______

There has never been a meeting among all agencies for this area.

_______

Other? Please explain other consultation procedures applicable to 

this

area.

______________________________________________________________________________

______

______________________________________________________________________________

______

______________________________________________________________________________

______

______________________________________________________________________________

______

Has the consultation process helped resolve difficulties related to

demonstrating conformity for a new project?

_____ Yes _____ No

Why or why not? Please briefly explain:

______________________________________________________________________________
______

______________________________________________________________________________

______

Other Comments on the Process

______________________________________________________________________________

______

______________________________________________________________________________

______

______________________________________________________________________________

______

______________________________________________________________________________

______

______________________________________________________________________________

______

______________________________________________________________________________

______

______________________________________________________________________________

______

______________________________________________________________________________

______

______________________________________________________________________________

______

______________________________________________________________________________

______

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